ML20053F013

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Forwards Signed & Notorized Affidavits of NRC Staff Who Participated in Updating Answers to Interrogatories & Requests for Admissions Prior to Apr 1977 or Who Answered NRDC & Sierra Club 820318 & 26 Interrogatories
ML20053F013
Person / Time
Site: Clinch River
Issue date: 05/14/1982
From: Swanson D
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To: Weiss E
National Resources Defense Council
References
NUDOCS 8206100305
Download: ML20053F013 (76)
v • d • e


Text

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DESIGNATED ORIGINAIl May 14, 1982 Certi ied by V

Ds~p 7 Ellyn R. Weiss Natural Resources Defense Council, Inc.

1725 Eye Street, N.W., Suite 600 Washington, D.C.

20006 In the Matter of UNITED STATES DEFf2.TMENT OF ENERGY PROJECT MANAGEMENT CORPORATION TENNESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor Plant)

Docket No. 50-537

Dear Ms. Weiss:

Enclosed are copies of the signed and notarized affidavits of the NRC Staff who participated in updating answers to interrogatories and requests for admissions in the case prior to April, 1977. Also included are the affidavits of those individuals who answered Natural Resources Defense Counsil, Inc. and the Sierra Club Twenty-second Set of Interrogatories to Staff filed on March 18, 1982 and Intervenors', Natural Resources Defense Council, Inc. and Sierra Club, Twenty-third Set of Interrogatories and Request tc Produce to the Staff filed on March 26, 1982.

Sincerely, Daniel T. Swanson Counsel for NRC Staff

Enclosures:

as stated cc:

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SATreb DATE :05/13/82
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05/8/82 8206100305 820514 PDR ADOCK 05000537 G

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION,

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of UNITED STATES DEPARTMENT OF ENERGY l

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION l

TENNESSEE VALLEY AUTHORITY

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(Clinch River Breeder Reactor Plant)

AFFIDAVIT OF CARDIS L. ALLEN I, Cardis L. Allen, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Reactor Engineer, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering the Request fer f

Admissions pertaining to Contention 2 (renumbered as 1) #81 through

  1. 95 and I hereby certify that the answers given are true to the best of my knowledge.

P Cardis L. Allen Subsc[ribed and sworn to before me this N day of. May,1982.

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My Commission expires:

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING OARD II In the Matter of l)l UNITED STATES DEPARTMENT OF ENERGYl Docket No. 50-537 PROJECT MANAGEMENT CORPORATION h

TENNESSEE VALLEY AUTHORITY l}l (Clinch River Breeder Reactt,r Plant) )

AFFIDAVIT OF JERRY J. SWIFT 1

1, Jerry J. Swift, being duly sworn, state as follows:

I am' employed by the U.S. Nuclear Regulatory Comission as a 1.

Reactor Engineer, Clinch River Breeder Reactor Program Office.

Office of Nuclear Reactor Regulation.

I am duly authorized to participate in answering the March 18, 1982 2.

9thRequestforAdmissions,SectionII,concerningContention3(re-numbered as 2) #1 through #6 and I hereby certify that the answers given are true to the best of my knowledge.

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.n' Subscribed and sworn to before me this day of. May,1982.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY CON 11SSION :

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD lll In the Matter of U.S. DEPARTMENT OF ENERGY l

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION l

TENNESSEE VALLEY AUTHORITY ll (Clinch River Breeder Reactor Plant) !)l AFFIDAVIT OF CARDIS L. ALLEN I, Cardis L. Allen, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a l

Project Manager, Clinch River Breeder Reactor Program Office,

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Office of Nuclear Reactor Regulation.

l 2.

I am duly authorized to participate in answering the August 13, 1976 Request for Admissions concerning contention 2 (renumbered as 1)

  1. 1 through #5 and I hereby certify that the answers given are true to the best of my knowledge.

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l C RDIS L. KLLEN Subsc ibed and sworn to before me this V_/ day of May,1982.

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My Comission expires: !/[fA

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UNITED STATES OF AMERICA NUCLEAR REGULATORY C0tt11SSION,, '

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD _

In the Matter of ll

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Docket No. 50-537 UNITED STATES DEPARTMENT OF ENERGY $l PROJECT MANAGEMEtiT CORPORATION l

TENNESSEE VALLEY AUTHORITY

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AFFIDAVIT OF ROBERT J. DUBE I, Robert J. Dube, being duly sworn, state as follows:

I am employed by the U.S. Nuclear Regulatory Comission as a 1.

Section Chief of Regulatory Activities and Analyses Section, Fuels Facilities Safeguards Licensing Branch, Division of Safe-guards, Office of Nuclear thterial Safety and Safeguards.

I am duly authorized to participate in answering the Request for 2.

Admissions pertaining to Contention 5 (renumbered as 4) #1 through 38 and I hereby certify that the answers given are true to the best of my knowledge.

M ROBERT J. D58E Subscribed and sw'orn to before me this f;.7* d h v 4 $, J982.h.}fj o April w.w, iEs o'nE{i,$3k.["fp

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Notary Pubiic My Comission expires: j I 'f 977 i

UNITED STATES OF AMERICA s

NUCLEAR REGULATORY COMMISSION,

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of UillTED STATES DEPARTHENT OF ENERGY I

Docket No. 50-537 I)l PROJECT MANAGEMENT CORPORATION TENilESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor

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Plant)

AFFIDAVIT OF HOMER LOWENBERG I, Homer Lowenberg, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as Chief Engineer, Office of Nuclear Material 56fety and Safeguards.

2.

I am duly authorized to participate in answering the Requests for Admissions pertaining to Contention 9 (renumbered as 6) #1 through 10 and I hereby certify that the answers given are true to the best of my knowledge.

HOMER LOWENBERG

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Subscribed and sworn to before me this 3*.* day of April,1982.

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0 UNITED STATES OF AMERICA NUCLEAR REGULATORY C0lfilSSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD s

In the Matter of ll lI Docket No. 50-537 UNITED STATES DEPARTMENT OF ENERGY PROJECT MANAGEMENT CORPORATION l

TENNESSEE VALLEY AUTHORITY lll (Clinch River Breeder Reactor ll Plant)

AFFIDAVIT OF ROBERT J. DUBE I, Robert J. Dube, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Section Chief of Regulatory Activities and Analyses Section, Fuels Facilities Safeguards Licensing Branch, Division of Safe-guards, Office of Nuclear Material Safety and Safeguards.

2.

I am duly authorized to participate in answering the Request for i

Admissions pertaining to Contention 5 (renumbered as 4) #39 through 56 and I hereby certify that the answers given are true to the best of my k.nowledge.

l 4 4rMA ROBERT J. DLIBE Subscribed and sworn to before ne l

this 7b'3 day of April,1982 m,7 7, gy, 3, NO1/Ay putu: : TATE OF lAAP.YLAND l

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UNITED STATES OF AMERICA NUCLEAR REGULATORY C0milSSION s

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of ll lI Docket No. 50-537 U.S. DEPARTMENT OF ENERGY PROJECT MANAGEMENT CORPORATION h

TENNESSEE VALLEY AUTHORITY ll (Clinch River Breeder Reactor Plant) )l AFFIDAVIT OF BILL M. MORRIS I, Bill M. Morris, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Section Leader of the Technical Review Section, Clinch River Breeder Reactor Program Office Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering the September 16, 1976 Request for Admissions concerning contention 5 (renumbered as 4) #50 and I hereby certify that the answers given are true to the best of my knowledge.

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EILL M. MORRIS Subscribed and sworn to before me this $ day.of May, 1982.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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U.S. DEPARTMENT OF ENERGY

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Docket No. 50-537 PROJECT MANAGEMENT CORPORATION

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TENNESSEE VALLEY AUTHORITH

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(Clinch River Breeder Reactor Plant) )

AFFIDAVIT OF MICHAEL BENDER I, Michael Bender, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Commission (NRC) as a Consultant through a contract between the Clinch River Breeder Reactor Program Office, NRC, and Brookhaven National Laboratories.

2.

I am employed by the Brookhaven National Laboratories as a Senior Scientist in the Medical Department.

3.

I am duly authorized to participate in answering the September 16, 1976 Request for Admissions concerning contention 8a (re-numbered as 11) #21 through #36, #41 and #42 and I hereby certify that the answers given are true to the best of my knowledge.

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MICHAEL BENDER I

Subscribed and sworn to before me this M day of May, 19 82. meme c4L, Lean a w 9... w v.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ','

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD e

lll In the Matter of U.S. DEPARTMENT OF ENERGY l

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION l

TENNESSEE VALLEY AUTHORITY h

(ClinchRiverBreederReactorPlant))I AFFIDAVIT OF JOHN V. NEHEMIAS I, John V. Nehemias, being duly sworn, state as follows:

1.

I am empicyed by the U.S. Nuclear Regulatory Comission as a Senior Health Physicist, Radiological Assessment Branch, Division of Systems Integration, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering the September 16, 1976 Request for Admissions concerning contention 8a (renumbered as 11) #36 through #40 and I hereby certify that the answers given are true to the best of my knowledge.

- i V. NEHEMIAS ~

Subscribed and sworn to before me this ay of May,1982.

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Notary Public My Comission expires: y[/f7)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COPtilSSION.

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ll

)I Docket No. 50-537 U.S. DEPARTMENT OF ENERGY PROJECT MAliAGEMENT CORPORATION lll TEtalESSEE VALLEY AUTHORITY

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(Clinch River Breeder Reactor Plant) )

AFFIDAVIT OF BILL M. MORRIS I, Bill M. Morris, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Section Leader of the Technical Review Section, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering the Request for Admission #1through#30concerningcontention3(renumberedas2)

I and I hereby certify that the answers given are true to the best of my knowledge.

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  1. 7 M BILL M. MORRIS Subscribed and sworn to before me l

thi

,' day of May,1982.

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UNITED STATES OF Af' ERICA liUCLEAR REGULATORY C0ttilSSION BE' FORE THE_ ATOMIC SAFETY Aft 0 LICEt:SI 'G FOAPD i.

i In the liatter of

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Docket No. 50-537 UtilTED STATES DEPARTMENT OF Et:ERGY PT,00ECT t'AFAGEPENT CORPORATION TENNESSEE VALLEY AUTit0RITY (Clinch River Ertedt.r Reactor

)

Plant)

AFFIDAVIT OF ROBERT J. DUBE I, Robert J. Dube, being duly sworn, state as follows:

I an employed by the U.S. Nuclear Regulatory Comission as a 1.

Section Chief of Regulatory Activities and Analyses Section, Fuel Facility Safeguards Licensing Branch, Division of Safe-guards, Office of Nuclear Material Safety and Safeguards.

I am duly authorized to participate in arswering the Request for 2.

AdmissionspertainingtoContention2(renumberedas1)#6through 30 and I hereby certify that the answers given are true to the j

best of ny knowledge.

l 1

ROBERT J. 'DUBE Subscribed and snorn to before me this fit c,f April, 1982.

MI ROBERT F. Ara!Y, JR, NOMY Misuc s; ATE OF MARYLAND Notary Public g fQ L m n n Expon J41,1982 My Comission expires:

6 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING E0ARD

- 1 In the Matter of

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P UNITED STATES DEPARTMENT OF ENERGY l

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION l

TENNESSEE VALLEY AUTHORITY ll

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(Clinch River Breeder Reactor Plant) ')

AFFIDAVIT OF CARDIS L. ALLEN I, Cardis L. Allen, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Reactor Engineer, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering the Requests for i

Admissions pertaining to Contention 2 (renumbered as 1), #31 l

through #80 and I hereby certify that the answers given are true to the best of my knowledge.

Cardis L. Allen Subscr bed and sworn to before me this

$dayof May,1982.

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Notary PubTic y

My Commission expires: M [A

s UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION s

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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l' UNITED STATES DEPARTMENT OF ENERGY l

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION l

TENNESSEE VALLEY AUTHORITY

)

(Clinch River Breeder Reactor Plant)

AFFIDAVIT OF EDWARD F. BRANAGAN, JR I, Edward F. Branagan, Jr., being duly sworn, state as follows:

1.

I an employed by the U.S. Nuclear Regulatory Comission as a Radiological Physicist, Radiological Assessment Branch, Division of Systems Integration, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatories #1,

  1. 10, #11, and #12 pertaining to Contention 8 (renumbered as 11) of the 22nd Set and I hereby certify that the answers given are true to the best of my knowledge, m

m Edward F. Branagan, Jr. /-

Subscribed and sworn to before me this /g;/4da'y' of May,1982.

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My Comission expires: /// [f.7

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i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION..

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BEFORE THE ATOMIC SAFETY AND LICENSING' BOARD t

In the Matter of

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UNITED STATES DEPARTMENT OF ENERGY h)

Docket No. 50-537 PROJECT ltANAGEMENT CORPORATION TENNESSEE VALLEY AUTHORITY

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(Clinch River Breeder Reactor Plant)

AFFIDAVIT OF BILL M. MORRIS I, Bill H. Morris, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Section Leader of the Technical Review Section, Clinch River Breeder Reactor i

Program Office, Office of Nuclear Reactor Regulation.

I am duly authorized to participate in answering Interrogatory IV, 2.

  1. 1 of the 22nd Set and I hereby certify that the answers given are true to the best of my knowledge.

$b m-44 Bill M. Morris l

Subscr bed and sworn to before me I

this_ 7/ day of May, 1982.

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' Notary Publ W

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My Comission expires:

UNITED STATES OF AMERICA NUCLEAR REGULATORY C0ttilSSION BEFORE THE ATOMIC SAFETY AND LICENSING'80ARD N

In the Matter of ll l'

UNITED STATES DEPARTMENT OF ENERGY l

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION

!I TENNESSEE VALLEY AUTHORITY lll (Clinch River Breeder Reactor Plant) ')

AFFIDAVIT OF JOHN V. NEHEMIAS I, John V. Nehemias, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Commission as a Senior Health Physicist, Radiological Assessment Branch, Division of Systems Integration, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatories #2 through #5 of Section II of the 22nd Set and I hereby certify that the answers given are true to the best of my knowledge, f

O n V. Nehemias Subscribed and sworn to before me this g, day of May, 1982.

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/lMic Notary PubliTc My Commission expires:

UNITED STATES OF AMERICA NUCLEAR REGULATORY C0ttilSSION BEFORE THE ATOMIC SAFETY AND LICENSING' BOARD l

)l In the Matter of UNITED STATES DEPARTMENT OF EllERGY l

Docket No. 50-537 PROJECT MANAGEMEtiT CORPORATION l}

TENNESSEE VALLEY AUTHORITY

l

')I (Clinch P,iver Breeder Reactor Plant)

AFFIDAVIT OF HOMER LOWENBERG I, Homer Lowenberg, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as Chief Engineer, Office of Nuclear Material Safety and Safeguards.

I am duly authorized to participate in answering Interrogatory #1(a) 2.

and (b) of the 22nd Set and I hereby certify that the answers given l

are true to the best of my knowledge.

HOMER LOWENBERG Subscribed and sworn to before me this 3 e day of. April, 1982.

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NotarfPublic l

My Comission expires:

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UNITEDSTATESOFdHERICA NUCLEAR REGULATORY C0tHISSION u

BEFORE THE ATOMIC SAFETY AND LICENSING SOARD S

In the Matter of ll

)l Docket No. 50-537 UNITED STATES DEPARTMENT OF ENERGY PROJECT MANAGEMENT CORPORATION l

TENNESSEE VALLEY AUTHORITY ll (Clinch River Breeder Reactor Plant)

AFFIDAVIT OF ROBERT J. DUBE I, Robert J. Dube, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Section Chief of Regulatory Activities and Analyses Section, Fuels Facilities Safeguards Licensing Branch, Division of Safe-guards, Office of Nuclear Material Safety and Safeguards.

2.

I am duly authorized to participate in answering Interragatories

  1. 1 and #20 of the 23rd Set and I hereby certify that the answers given are true to the best of my knowledge.

1 AL&l ROBERT J. DtEE Su scr a

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Notary'Public hI r r-My Comission expires:

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NOTARY PUEUC ETA E CF !AA."YL/,NO My ccmcisiron txp;res My 1,1982

i UNITED STATES OF AMERICA NL' CLEAR REGULATORY C0tNISSION BEFORE THE ATOMIC SAFETY AND LICENSING SOARD In the Matter of

)I UNITED STATES DEPARTMENT OF ENERGY $

Docket No. 50-537 PROJECT ltANAGEMENT CORPORATION 9

TENNESSEE VALLEY AUTHORITY h

(Clinch River Breeder Reactor Plant) )I AFFIDAVIT OF JOHN V. NEHEMIAS I, John V. Nehenias, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Senior Health Physicist, Radiological Assessment Branch, Division of Systems Integration, Office of Nuclear Reactor Regulation.

2.

I an duly authorized to participate in answering the July 28, 1976 Requests for Admissions pertaining to Contention 8a (renumbered as 11)

  1. 1, #2, #13 through #16, #19 and #20 and I hereby certify that the answers given are true to the best of my knowledge.

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Subscr bed and sworn to before me this 8 day of May, 1982.

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Jfm Notary Publid My Comission expires: fj(

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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UNITED STATES DEPARTMENT OF ENERGY

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Docket No. 50-537 PROJECT MANAGEMENT CORPORATION

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TENNESSEE VALLEY AUTHORITY

)

)

(Clinch River Breeder Reactor Plant) )

AFFIDAVIT OF MICHAEL BENDER I, Michael Bender, being duly sworn, state as follows:

(NRC)

I am employed by the U.S. Nuclear Regulatory Commission 1.

as a Consultant through a contract between the Clinch River Breeder Reactor Program Office, NRC, and Brookhaven National Laboratories.

I am employed by the Brookhaven National Laboratories as a 2.

Senior Scientist in the Medical Department.

3.

I am duly authorized to participate in answering the 1976 Request for Admissions pertaining to Contention July 28, 8a (renumbered r

as 11, #4, 95, 98, 89, #11, 012, ank #17 and I hereby certify that the answers given are true to the best of my knowledge" MICHAEL BENDER Subscribed and sworn to before me this dr day of May, 1982.

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i UNITED STATES OF AMERICA NUCLEAR REGULATORY COPHISSION.

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD _

)

In the Matter of

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Docket No. 50-537

)1 UNITED STATES DEPARTMENT OF ENERGY PROJECT MANAGEMENT CORPORATION h TENNESSEE VALLEY AUTHORITY j

h (Clinch River Breeder Reactor

)

Plant)

AFFIDAVIT OF HOMER LOWENBERG I, Homer Lowenberg, being duly sworn, state as follows:

I am employed by the U.S. Nuclear Regulatory Comission as 1.

Chief Engineer, Office of Nuclear Material Safety and Safeguards.

I am duly authorized to participate in answering the Requests for 2.

Admissions pertaining to Contention 7 (renumbered as part of 11)

  1. 1 through #5 and I hereby certify that the answers given are true to the best of my knowledge.

HOMER LOWENBERG Subscribed and sworn to before me this N' day of April,1982.

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1 UNITEDSTATESOFkMERICA NUCLEAR REGULATORY C0ttlISSION

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BE' FORE THE ATOMIC SAFETY AND LICENSING BOARD i'

In the Matter of ll ll Docket No. 50-537 UNITED STATES DEPARTMENT OF ENERGY PROJECT ttANAGEliENT CORPORATION l

TENNESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor Plant)

AFFIDAVIT OF EDWARD F. BRANAGAN, JR I, Edward F. Branagan, Jr., being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Radio 1ngical Physicist, Radiological Messment Branch, Division of Systems Integration, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering the July 28, 1976 Requests for Admissions certaining to contention 7 (renumbered as 11)

  1. 6 through #33; pertaining to contention 8a (renumbered as 11) #3, #6,
  1. 7, #9, #10, #17 and #18; pertaining to contention 8c (renumbered as 11) #1 through #19 and I hereby certify that the answers given are true to the best of my knowledge.

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Edward F. Branagan, Jr.

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Subscribed and orn to before me g /fiday of May, 1982.

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7//[g Wotary Publi'c' My Comission expires:

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UNITED STATES OF ' AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING _ BOARD In the Matter of

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l UNITED STATES DEPARTMENT OF ENERGY I

Docket No. 50-537 PROJECT MANAGEt1ENT CORPORATION l

lJ TENNESSEE VALLEY AUTHORITY

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(Clinch River Breeder Reactor Plant) )

AFFIDAVIT OF EDWARD F. BRANAGAN, JR.

I, Edward F. Branagan, Jr., being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Radiological Physicist, Radiological Assessment Branch, Division of Systems Integration, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatories

  1. 10, #13, and #14 of the 19th Set and I hereby certify that the answers given are true to the best of my knowledge.

A T

Edward F. Branagan, Jr.

I Subscribed and sworn to before me l

this M day of May, 1982.

1 (d)/h dh YM Notary Public My Comission expires: 7/'((p

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMISSION

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ll ll Docket No. 50-537 UNITED STATES DEPARTMENT OF ENERGY i

PROJECT MANAGEMENT CORPORATION l

TENNESSEE VALLEY AUTHORITY l

(Clinch River Breeder Reactor

)

Plant)

AFFIDAVIT OF HOMER LOWENBERG I, Homer Lowenberg, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as Chief Engineer, Office of Nuclear Material Safety and Safeguards.

2.

I am duly authorized to participate in answering Interrogatory # 17a of the 19th Set and I hereby certify that the answers given are true to the best of my knowledge.

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HOMER LOWENBERG Subscribed and sworn to before me this 30* day of. April, 1982.

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-Lu - A \\M Notary Public My Comission expires:

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND 1.ICENSING. B0d'RD In the Matter of p

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UNITED STATES DEPARTMENT OF ENERGY

'I Docket No. 50-537 d

PROJECT MANAGEMENT CORPORATION i

TENNESSEE VALLEY AUTHORITY ll l

(Clinch River Breeder Reactor Plant) ')

AFFIDAVIT OF EDWARD F. BRANAGAN, JR.

I, Edward F. Branagan, Jr., being duly sworn, state as follows:

I am employed by the U.S. Nuclear ReSulatory Comission as a 1.

Radiological Physicist, Radiological Assessment Branch, Division of Systems Integration Office of Nuclear Reactor Regulation.

I am duly authorized to participate in answering Interrogatories #84 2.

l through #89 of the 20th Set and I hereby certify that the answers given j

are true to the best of my knowledge.

i 94~MB~,/ ',

EDWARD F. BRANAGAN, JR.

Subscribed and sworn to before me this g day.pf May,1982.

80hJW 3LLL1/

NOTARY PUBLlC

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My Commission expires:

UNITED STATES OF' AMERICA NUCLEAR REGULATORY C0t9tISSION

__B_EFORETHEATOMICSAFETYANDLICENSINhBOARD

)i In the Matter of U.S. DEPARTMENT OF ENERGY I

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION l

TENNESSEE VALLEY AUTHORITY ll l

(ClinchRiverBreederReactorPlant)')

AFFIDAVIT OF M0HAN C. THADANI I, Mohan C. Thadani, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Nuclear Engineer, Accident Evaluation Branch, Division of Systems Integration, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatories

  1. 46, #47, #48, #49, #50, #51, #52, #53, #74, #75 of the 20th Set and I hereby certify that the answers given are true to the best l

of my knowledge.

l

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Pl0HAN C. THADANI Subscribgd and -sworn to before me this

_May of(May, 1982.

l

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N'otary Public My Comission expires: [

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UNITED STATES OF AMERICA NUCLEAR REGULATORY C0t#11SSION,

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD h'

In the Matter of U.S. DEPARTMENT OF ENERGY Docket No. 50-537 PROJECT MANAGEMENT CORPORATION TEtiNESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor Plant)

AFFIDAVIT OF RICHARD BECKER I, Richard Becker, being duly sworn, state as follows:

1.

I an employed by the U.S. Nuclear Regulatory Comission as a Reactor Engineer, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatories l

  1. 1 through #45, #49, #53, #82, and #83 of the 20th Set and I hereby certify tht the answers given are true to the best of my knowledge.

1 dYhnlzu l

RICHARD BECKER l

Subscribed and sworn to before me j

this fjday of 'May,1982.

Abb 2n s

Notary Public My Comission expires: 7///[A

UNITED STATES OF AMERICA NUCLEAR REGULATORY CORilSSION BEFORE THE ATOMIC SAFETY AND LICENSING'10ARD D

lll In the Matter of UNITED STATES DEPARTMENT OF ENERGY l

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION l

TENNESSEE VALLEY AUTHORITY l

l l

(ClinchRiverBreederReactorPlant)ll AFFIDAVIT OF JERRY J. SWIFT I, Jerry J. Swift, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Commission as a Reactor Engineer, Clinch River Breuer Reactor Program Office, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatories

  1. 74 to
  1. 76 of the 20th Set and I hereby certify that the answers given are true to the best of my knowledge.

l 3

1, Subscribed and sworn to before me this[t/ day of May,1982.

/

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Notary PubTTc' My Comission expires: f/,

UNITED STATES OF A'MERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING' BOARD'

{

'I In the Matter of l)l Docket No. 50-537 UNITED STATES DEPARTMENT OF ENERGY ll PROJECT MANAGEt1ENT CORPORATION l

TENNESSEE VALLEY AUTHORITY

)

)I (Clinch River Breeder Reactor Plant)

AFFIDAVIT OF PAUL LEECH I, Paul Leech, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Project Manager, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

I am duly authorized to participate in answering Interrogatories 2.

  1. 70 through #73, #76 and #90 of the 20th Set and I hereby certify that the answers given are true to the best of my knowledge.

l C

.u -

PAUL LEECH Subscribed and sworn to before me this / fj/ day of May,1982.

4$101 l

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' Notary PubliU'-

My Comission expires:

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD-

~.

N ll)

In the Matter of UNITED STATES DEPARTMENT OF ENERGY l

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION ll TENNESSE2 VALLEY AUTHORITY

l I

(Clinch River Breeder Reactor Plant) ')

AFFIDAVTT OF RICHARD M. STARK I, Richard M. Stark, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comist in as a Project Manager, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatory #90 of the 20th Set and I hereby certify that the answers given are true to the best of my knowledge.

b Qtf

'y RICHARD M' STARK Subscribed and sworn to before me thisff_/ day of May,1982.

Wfi JA*

Notary Public My Comission ex'pires: r/[

l l

l

4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD lll In the Matter of U.S. DEPARTMENT OF ENERGY l

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION l

TENNESSEE VALLEY AUTHORITY lll (ClinchRiverBreederReactorPlant)')

AFFIDAVIT OF JOHN K. LONG I, John K. Long, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Nuclear Engineer, Research Systems Branch, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatories

  1. 1 through #45, #49, #53, #54, #63, #64, #65, #66, #67, #68, #69,
  1. 77, #78, #82 and #83 of the 20th Set and I hereby certify that the answers given are true to the best of rqy knowledge.

P Y

YW MG JOHN K.

LONG

/

Subscriedandshorntobeforeme this day of May,1982.

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Notary Public My Commission expires:

My Come.is,1m Errires Onober 1+ 198!

s UNITED STATES OF AMERICA s

NUCLEAR REGULATORY C0ffilSSION s

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l:

In the Matter of

'l' l

UNITEDSTATESDEPARTMENTOFENERGYll Docket No. 50-537 PROJECT !!ANAGEMENT CORPORATION I

TENNESSEE VALLEY AUTHORITY ll (Clinch River Breeder Reactor ll}

Plant)

,1 AFFIDAVIT OF MICHAEL KALTMAN I, litchael Kaltman, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission.as a Regional Planning Analyst, Siting Analysis Branch, Division of Engineering, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatories

  1. 79, #80 and #81 of the 20th Set and I hereby certify that the answers given are true to the best of my knowledge.

)

Michael Kaltmsn' Subscribed.and sworn to before me this

_ day,0f May,1982.

/}bHE

'X 1 c L -

Notary Pub 1Tc "

My Comission expires: ff

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICEN3ING4 0ARD

)l In the Matter of UNITED STATES DEPARTMENT OF ENERGY I

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION l

)l TENNESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor Plant) h AFFIDAVIT OF CARDIS L. ALLEN I, Cardis L. Allen, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Reactor Engineer, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatories #1 through #12 of the 21st Set and I hereby certify that the answers given are true to the best of my knowledge.

Cardis L. Allen Subscr bed and sworn to before me l

this

& day of May, 1982.

1 n/$

d N6tary Public My Comission expires: 14[fA l

i 1

UNITFn STATES OF AMERICA NUCLEAR REGULATORY CON 4ISSION..

BE' FORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

)

UNITED STATES DEPARTMENT OF ENERGY Docket No. 50-537 PROJECT MANAGEf1ENT CORPORATION j

TENNESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor Plant AFFIDAVIT OF SHLOMO S. YANIV, Sc.D.

I, Shlomo S. Yaniv, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Radiological and Health Effects Specialist, Health Effects Branch, Division of Health, Siting, and Waste Management, Office of Nuclear Regulatory Research.

2.

I am duly authorized to participate in answering Interrogatories #6,

  1. 7, #8 and #9 of Section II of the 22nd Set and I hereby certify l

that the answers given are true to the best of my knowledge.

I i

f lomo S. Yaniv, Sc.D.

Subscrigdandsworntobeforeme this f day of May, 1982.

l ROBI7T r. ASEtt, Jr.

[,

/

NOTA %Y FUE*dC STATE OF ME;YLeig; e446 l

My Commission Expires July 1,1932 Notary Public j

My Comission expires:

[

'M f

UNITED STATES OF AMERICA NUCLEAR REGULATORY C0ttlISSION 2-BE' FORE THE ATOMIC SAFETY AND LICENSING BOARD L

In the Matter of U.S. DEPARTMENT OF ENERGY Docket No. 50-537 PROJECT MANAGEMENT CORPORATION TENNESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor Plant) )

AFFIDAVIT OF JOHN K. LONG I, John K. Long, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Commission as a Nuclear Engineer, Research Systems Branch, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatories

  1. 1,#3, #I2 of the 17th Set and I hereby certify that the answers given are true to the best of my knowledge.

O i

l A

( (

OK J N K. LONG SubscrJbed and sworn to before me this.5 day of'May 1982.

AA b'A Notary Public My Commission expires:

y Cornminion Expire one,

,gggy

UNITED STATES 0F AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD _

k

)0 In the Matter of I

Docket No. 50-537 U.S. DEPARTMENT OF ENERGY PROJECT MANAGEMENT CORPORATION ll TENNESSEE VALLEY AUTHORITY J

l (ClinchRiverBreederReactorPlant)')

AFFIDAVIT OF CARDIS L. ALLEN I, Cardis L. Allen, being duly sworn, state as follows:

I am employed by the U.S. Nuclear Regulatory Connission as a 1.

Reactor Engineer, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

I am duly authorized to participate in answering Interrogatories #4, 2.

  1. 8 through #11 of the 17th Set and I hereby certify that the answers given are true to the best of my knowledge.

A CARDIS L. ALLEN Subscribed and sworn to before me this gday of,May,1982.

f 4/ J Notary Public (j

My Commission expires: 7h [A

.n UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING-10ARD C

In the Matter of

})

~

UNITED STATES DEPARTMENT OF ENERGY h

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION h

TENNESSEE VALLEY AUTHORITY

)

(Clinch River Breeder Reactor Plant)

AFFIDAVIT OF HOWARD B. HOLZ I, Howard B. Holz, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Systems Engineer, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatories #1 l

and #2 of the 18th Set and I hereby certify that the answers given f

are true to the best of my knowledge.

I Howard B. Holz Sub' scribed and sworn to before me this y'M_ day of May,1982.

/i b h b W f

(/

' Notary Public My Comission expires: gf[f'q

e UNITED STATES OF AMERICA i

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i

~

))

In the Matter of UNITED STATES DEPARTMENT OF ENERGY l

Docket No. 50-537 b)

PROJECT MANAGEMENT CORPORATION TENNESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor Plant)

AFFIDAVIT OF BILL M. MORRIS I, Bill M. Morris, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Section Leader of the Technical Review Section, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatories #1 and #2 of the 18th Set and I hereby certify that the answers given are true to the best of my knowledge.

hdl #7 M w Bill M. Morris Subscribepandsworntobeforeme May,1982.

thisg/gfdayof.

f41h$1J YWE Notary Public My Comission expires: g

UNITED STATES OF AMERICA NUCLEAR REGULATORY C0FNISSION

~

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

~.~'

In the Matter of p

i UNITED STATES DEPARTMENT OF ENERGY l

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION l

TENNESSEE VALLEY AUTHORITY ll (Clinch River Breeder Reactor Plant)

AFFIDAVIT OF RICHARD M. STARK I, Richard M. Stark, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Project Manager, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatories #1 and #2 of the 18th Set and I hereby certify that the answers given l

are true to the best of my knowledge.

A4 f

Richard M. Stark Subscribed and sworn to before me this

/fdayof May, 1982.

Af0 t

Notary PublW L '

My Comission expires: f/f 1

f

em' UNITED STATES OF AMERICA NUCLEAR REGULMORY COMMISSION q

BEFORE THE ATOMIC SAFETY AND LICENSING 40ARD

?

))

In the Matter cf UNITED STATES DEPARTMENT OF ENERGY h

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION 1

TENNESSEE VALLEY AUTHORITY p

I (ClinchRiverBreederReactorPlant)h AFFIDAVIT OF CARDIS L. ALLEN f

I, Cardis L. Allen, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Reactor Engineer, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatories #1 and #2 of the 18th Set ano I hereby certify that the answers given are true to the best of my knowledge.

\\

e Cardis L. Allen Subscribed and sworn to before me thisg(dayof May, 1982.

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1]/-kn

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y Notary PubTicV My Comission expires: %/ f)_ /

UNITED STATES OF AMERICA i

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD--

~

In the Matter of l1 b)

Docket No. 50-537 UNITED STATES DEPARTMENT OF ENERGY h

PROJECT MANAGEMENT CORPORATION TENNESSEE VALLEY AUTHORITY

)>

(ClinchRiverBreederReactorPlant))

AFFIDAVIT OF RICHARD BECKER I, Richard Becker, being duly sworn, state as follows:

I am employed by the U.S. Nuclear Regulatory Comission as a 1.

Reactor Engineer, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

I am duly authorized to participate in answering Interrogatories 2.

  1. 2, #17 through #40, #48 and #49 of the 19th Set and I hereby certify that the answers given are true to the best of my knowledge.

AuJrex Richard Becke?

1 Subscr' bed and sworn to before me i

this /j/ay of May, 1982.

A%t/N ibss _1/

' Notary PubTic g

My Comission expires: 7[/ A l

UNITED STATES OF AMERICA NUCLEAR REGULATORY C0 MISSION BEFORE THE ATOMIC SAFETY AND LICENSING. BOARD I.

In the flatter of

}I UNITED STATES DEPARTMENT OF ENERGY l

Docket No. 50-537

$l PROJECT MANAGEMENT CORPORATION TENNESSEE VALLEY AUTHORITY l

(ClinchRiverBreederReactorPlant)')

AFFIDAVIT OF RICHARD M. STARK I, Richard M. Stark, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Commission as a Project Manager, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatory #50 of the 19th Set and I hereby certify that the answers given are true to the best of my knowledge.

RICHARD fl. STARK Subscribgd and sworn to before me

/

this, Gday of May,1982.

/AIli1Y 1/m Notary Public

~

M,C _ ission e,,1,.s g,(e,

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING': BOARD

}I In the Matter of UNITED STATES DEPARTMENT OF ENERGY Docket No. 50-537 PROJECT MANAGEMENT CORPORATION h

TENNESSEE VALLEY AUTHORITY

!)

(Clinch River Breeder Reactor Plant) )l AFFIDAVIT OF JOHN V. NEHEMIAS I, John V. Nehemias, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Senior Health Physicist, Radiological Assessment Branch, Division of Systems Integration. Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatories

  1. 11, #12, #15 and #16 of the 19th Set and I hereby certify that the answers given are true to the best of my knowledge.

V.

Q n~V. Nehemias Subscribed and sworn to before me this //'y day of May,1982.

b/bsfX

/ll ww L--

' Notary PuSTic

/

My Comission expires: 1/,,

UNITED STATES OF AMERICA NUCLEAR REGULATORY C0tHISSION m.

~

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

'l' UNITEDSTATESDEPARTMENTOFENERGYl)l Docket No. 50-537 PROJECT MANAGEMENT CORPORATION l

TENNESSEE VALLEY AUTHORITY ll l)ll (Clinch River Breeder Reactor Plant)

AFFIDAVIT OF MICHAEL KALTMAN I, Michael Kaltman, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Regional Planning Analyst, Siting Analysis Branch, Division of Engineering, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatory #9 of the 19th Set and I hereby certify that the answers given are true to the best of my knowledge.

Michael Kaltman Subscribed and sworn to before me this f day o May

, 1982.

Of)ilt b *t i

l

' Notary Public My Comission expires:

77,

7

e

~

UNITFD STATES OF AMERICA NUCLEAR REGULATORY C0tMISSION BEFORE THE ATOMIC SAFETY AND LICENSING. BOAR'D

?.

}l In the Matter of UNITED STATES DEPARTMENT OF ENERGY l

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION h

TENNESSEE VALLEY AUTHORITY lll (Clinch River Breeder Reactor

')

Plant)

AFFIDAVIT OF PAUL LEECH I, Paul Leech, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Project Manager, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatories l

  1. 5, E, #7, #50 of the 19th Set and I hereby certify that the answers given are true to the best of sqy knowledge.

Y 9

PAUL LEECH Subscri ed and sworn to before me this day of May, 1982.

k //A v WW Notary Public g

My Comission exp~ ires: 7//7fg l

i

f 1

UNITED STATES OF, AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

))

U.S. DEPARTMENT OF ENERGY l

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION l

TENNESSEE VALLEY AUTHORITY l

l

)

(Clinch River Breeder Reactor Plant) ')

AFFIDAVIT OF JOHN K. LONG I, John K. Long, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Nuclear Engineer, Research Systems Branch, Office of Nuclear Reactor Regulation.

I am duly authorized to participate in answering Interrogatories #2, 2-f

  1. 17 through #40, #48, #49 of the 19th Set and I hereby certify that the answers given are true to the best of my knowledge.

t d~ k cm l

i JOHN K. LONG Subscri d and gworn to before me this day of May.,1982.

/k lN o l bnf l

Notary Public My Comission expires:

hty,Cemmasion Expires October 14. 1981

e UNITED STATES OF AMERICA w

NUCLEAR REGULATORY COMMISSIONS BEFORE THE ATOMIC SAFETY AND LICENSING' BOARD s

I In the Matter of UNITED STATES DEPARTMENT OF ENERGY

'1 Docket No. 50-537 PROJECT MANAGEMENT CORPORATION TENNESSEE VALLEY AUTHORITY lll l

(Clinch River Breeder Reactor Plant) !)

AFFIDAVIT OF PETER B. ERICKSON I, Peter B. Erickson, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Project Manager, Standardization and Special Projects Branch, Division of Licensing, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatories #2 l

and #3 pertaining to Contention 14 (renumbered as 8) of the 10th Set and I hereby certify that the answers given are true to the best of my knowledge.

'l Peter B. Erickson Subscr bed and sworn to before me this fjdayofMay 1982.

//YAA0 AHhv

' Nota ~rf7uoTit g

My Comission expires: f g

UNITED STATES OF' AMERICA NUCLEAR REGULATORY COMMISSION

'BEFORETHEATOMICSAFETYANDLICENSING}BOAltD i

i In the Matter of UNITED STATES DEPARTMENT OF ENERGY Docket No. 50-537 PROJECT MANAGEMENT CORPORATION l

TENNESSEE VALLEY AUTHORITY ll (ClinchRiverBreederReactorPlant)!>)

AFFIDAVIT OF BILL M. MORRIS I, Bill M. Morris, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Section Leader of the Technical Review Section, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

l 2.

I am duly authorized to participate in answering Interrogatories #1 through #68 and #70 through #100 of the lith Set and I hereby certify that the answers given are true to the best of my knowledge.

I

$ A 1 A A n' Bill M. Morris Subscribed and sworn to before me thisg7jfday of May, 1982.

  1. AN M

l Notary PubHc g

My Comission expires: 7, 8

1 n-

,--r e,.

s-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING 10ARD D

In the Matter of

)l UNITED STATES DEPARTMENT OF ENERGY

)

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION

)

TENNESSEE VALLEY AUTHORITY

)

)

(Clinch River Breeder Reactor Plant) )

AFFIDAVIT OF JERRY J. SWIFT I, Jerry J. Swift, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Reactor Engineer, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to partic;pate in answering Interrogatory #69 of the lith Set and I hereby certify that the answers given are true to the best of my knowledge.

0 R

~

~

i erryJ/ Swift f

r Subscribed and sworn to before me this day of May,1982.

n.

Yi Aban s

Kotary Tublic-l My Comission expires: '7 p

I

UNITFn STATES OF AMERICA 4

NUCLEAR REGULATORY COMISSION c

c BE' FORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of UNITED STATES DEPARTMENT OF ENERGY Docket No. 50-537 PROJECT MANAGEMENT CORPORATION TENNESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor Plant)

AFFIDAVIT OF EDWARD F. BRANAGAN, JR I, Edward F. Branagan, Jr., being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Radiological Physicist, Radiological Assessment Branch, Division of Systems Integration, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatories #6, through #10 of Section III of the 12th Set and I hereby certify that the answers given are true to the best of my knowledge.

Edward F. Branagan, Jr.

/

Subscribed and sworn to before me thi.5-j f,ff day of May, 1982.

tf M h ( b 4/M+

Notary Public' f

My Comission expires:

/

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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING SOARD In the Matter of

'l

)

UNITED STATES DEPARTMENT OF ENERGY h Docket No. 50-537 PROJECT MANAGEMENT CORPORATION j

TENNESSEE VALLEY AUTHORITY l)l (ClinchP,iverBreederReactorPlant)

AFFIDAVIT nF SHLOMO S. YANIV, Sc.D.

I, Shlomo S. Yaniv, being duly sworn, state as follows:

I am employed by the U.S. Nuclear Regulatory Comission as a 1.

Radiological and Health Effects Specialist, Health Effects Branch, Division of Health, Siting, and Waste Management, Office of Nuclear Regulatory Research.

I am duly authorized to participate in answering Interrogatories in l

2.

Section I, #1 through #5,Section II, #1 through #39 and Section III,

  1. 1 through #5 of the 12th Set and I hereby certify that the answers given are true to the best of my knowledge.

~~

)

/ Shlomo 5. Yaniv, Sc.D.

Sut' scribed and sworn to before me l

this 5% day of May,1982.

I ROBDT F. ABBEY, R.

/

v g/

NOTARY PUBUC STATE OF MARY 1.AND g

My Commission Expires July 1,1982 My Comission expires: J I NIL I

s UNITED STATES OF AMERICA s

NUCLEAR REGULATORY COMMISSION,

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of U.S. DEPARTMENT OF ENERGY Docket No. 50-537 PROJECT mat:AGEt1ENT CORPORATION TENNESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor Plant) )

AFFIDAVIT OF BILL M. MORRIS I, Bill M. Morris, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Section Leader of the Technical Review Section, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

l l

2.

I am duly authorized to participate in answering Interrogatories #1 through #54 of the 13th Set and I hereby certify that the answers I

(

given are true to the best of my knowledge.

l A e's m O2.~,2 BILL ~M.

MORRIS Subscribed and sworn to before me j

this g ay of 'May, 1982.

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Nota,,,.,m c M,C _ ission ex,1,es; g a

UNITED STt.TES OF AMERICA NUCLEAR REGULATORY COMMISSION 4

3 BEFORE THE ATOMIC SAFETY AND LICENSING BOXRD

)))

In the Matter of Docket No. 50-537 i

UNITED STATES DEPARTMENT 9F ENERGY PROJECT MANAGEMENT CORPORATION J)

TENNESSEE VALLEY AUTHORITY

)

(Clinch River Breeder Reactor Plant) )

AFFIDAVIT OF BILL M. MORRIS I, Bill M. Morris, being duly sworn, state as follows:

I am employed by the U.S. Nuclear Regulatory Comission as a Section 1.

Leader of the Technical Review Section, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

I am duly authorized to participate in answering #1 of Section IV #1 2.

of the 14th Set and I her~eby certify that the answers given are true to the best of my knowledge.

t Y #f /$%

Bill M. Morris Subscribed and sworn to before me this gdayof May, 1982.

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a UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of~

UNITED STATES DEPARTMENT OF ENERGY I

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION

!)

TENNESSEE VALLEY AUTHORITY

l (Clinch River Breeder Reactor Plant) !))

AFFIDAVIT OF JERRY J. SWIFT I, Jerry J. Swift, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Reactor Engineer, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

I am duly authorized to participate in answering Interrogatories #3 2.

of Section II; il through #3 of Section V, il of Section VI and #1 of l

l l

Section VII of the 14th Set and I hereby certify that the answers given are true to the best of my knowledge.

O n

lehr rryo.ySwift'

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Subscribed and sworn to before me this M day of._, May,1982.

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UNITED STATES OF AMERICA NUCLEAR RFSULATORY COMMISSION

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BEFORE THE ATOMIC SAFETY AND LICENSIN(bB0ARD M

In the Hatter of l}

l UNITED STATES DEPARTMENT OF ENERGY l

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION l

TENNESSEE VALLEY AUTHORITY ll (Clinch River Breeder Reactor Plant) !)l AFFIDAVIT OF CARDIS L. ALLEN I, Cardis L. Allen, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Reactor Engineer, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatories #1 - #4 of Section I, #1 and #2 of Section II, #1 and #2 of Section III, #1 of Section VIII and #1 through #5 of Section IX of the 14th Set and I hereby certify that the answers given are true to the best of my knowledge.

4

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Cardis L. Allen Subscribed and sworn to before me this f{/ day of',May,1982.

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Notary Pubnc My Comission expires: 7[/

4

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UNITED STATES bF AbERICA NUCLEAR REGULATORY C0tHISSION BEFORE THE ATOMIC SAFETY AND LICENSING-ROARd I I In the Matter of

)l UNITED STATES DEPARTMENT OF ENERGYh Docket No. 50-537 PROJECT MANAGEMENT CORPORATION h)

TENNESSEE VALLEY AUTHORITY

'l (Clinch River Breeder Reactor Plant) ')

AFFIDAVITOFH6WARDB.HOLZ I, Howard B. Holz, being duly sworn, state as follows:

I am employed by the U.S. Nuclear Regulatory Comission as a 1.

Systems Engineer, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

I am duly authorized to participate in answering Interrogatories #1 2.

through #6 of the 16th Set and I hereby certify that the answers given are true to the best of my knowledge.

f- _ =Ydh/

HOWARD B. HOLZ Subscribed and sworn to before me this y day of May, 1982.

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Notary Public f/,[g My Comission exp' ires:

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v UNITED STATES OF AMERICA NUCLEAR REGULATORY COWilSSION z

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of U.S. DEPARTMENT OF ENERGY Docket No. 50-537 PROJECT MANAGEMENT CORPORATION TENNESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor Plant)

AFFIDAVIT OF RICHARD BECKER I, Richard Becker, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Reactor Engineer, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatories

  1. 1, #3, #12 of the 17th Set and I hereby certify that the answers given are true to the best of my knowledge.

$bW RICHARD BECKER Subscrib d and sworn to before me thi

. day of ',May,1982.

4/AJElb JIM' Notary FubMc My Comission expires: f/f

0 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSIN'G B0 RD In the Matter of U.S. DEPARTMENT OF ENERGY Docket No. 50-537 PROJECT MANAGEMENT CORPORATION TENNESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor Plant) )

AFFIDAVIT OF JOHN K. LONG I, John K. Long, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Nuclear Engineer, Research Systems Branch Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering the Interrogatories in the 7th Set and I hereby certify that the answers given are true to the best of my knowledge.

i l

l i

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CLM k, JC N K. LONG j

Subscribed and sworn to before me this 4 day of May

,1982.

asLA Notary Public My Conunissic 1 expires:

My Cemeisiin Exphs Ocober 14,198?

L

UNITED STATES OF AMERICA NUCLEAR REGULATORY, COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Ma'tter of.

)

t Docket No. 50-537 i

UNITEDSTATESDEPARTMEt;TOFENERGY)

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)

PROJECT MAtlAGEMENT CORPORATION

)

TENtiESSEE VALLEY AUTHORITY

)))

(Clinch River Breeder Reactor Plant)

AFFIDAVIT OF CARDIS. L. ALLEN L. Allen, being duly sworn, state as follows:

I, Cardis I am employed by the U.S. Nuclear Regulatory Comission as a 1.

Office Reactor Engineer, Clinch River Breeder Reactor Program Office, of Nuclear Reactor Regulation.

I am duly authorized to participate in answering Interrogatories #1 2*

through #4 of Section I of the 8th Set and I hereby certify that the answers given are true to the best of my knowledge.

A CARDIS L. ALLEN Subscr bed and sworn to before me this rf day of May,

198 2.

luM A lo-w o f Notary Publti:

My Comission expires: 1<((A

UNITEDSTATESOFkMERICA NUCLEAR REGULATORY C0tEISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD P

In the Matter of ll l

UNITED STATES DEPARTMENT OF ENERGY l

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION ll TENNESSEE VALLEY AUTHORITY l

)

(Clinch River Breeder Reactor Plant) ')

AFFIDAVIT OF JERRY J. SWIFT I, Jerry J. Swift, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Reactor Engineer, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatories #1 through #7 in Section II of the 8th Set and I hereby certify that the answers given are true to the best of my knowledge.

h l]/

1 Subscribed and sworn to before me this

<j day of May,1982.

ti)Tl/1N

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Notary Public My Comission expires: 7///[g 1

UNITED STATES OF AMERICA NUCLEAR REGULATORY COWilSSION BEFORE THE ATOMIC SAFETY AND LICENSING. BOARD" F

In the Matter of

))

UNITED STATES DEPARTMENT OF ENERGY h'

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION l

TENNESSEE VALLEY AUTHORITY l

)I (Clinch River Breeder Reactor Plant)

AFFf3AVIT OF ROBERT J. DUBE I, Robert J. Dube, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Section Chief of Regulatory Activities and Analyses Section, Fuels Facilities Safeguards Licensing Branch, Division of Safe-guards, Office of Nuclear Material Safety and Safeguards.

2.

I am duly authorized to participate in answering Interrogatories in Section IV, #1 through #5;Section V, #1 through #6;Section VI,

  1. 1 through #6;Section VII, #1 through #6;Section VIII, #1 and #2;Section IX, #1 and #2; and Section X, #1 and #2 of the 8th Set and I hereby certify that the answers given are true to the best of my knowledge.

ROBERT J. DtfBE Subscribed and sworn to before me RosF.RT F. ACBEY. JR.

this 13

  • day of April, 1982.

NOTARY PUEllC STATE CF MAPYLAND I

h My Ccmmission Empires July 1,1982 r

a notary vuonc My Comission expires: [

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMISSION,

{..

BEFORE THE ATOMIC SAFETY AND LICENSING. BOARD

))

In the Matter of UNITED STATES DEPARTMENT OF ENERGY h

Docket No. 50-537 h))

PROJECT MANAGEMENT CORPORATION TEtiNESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor

')

Plant)

AFFIDAVIT OF LARRY W. BELL I, Larry W. Bell, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Nuclear Engineer with the Accident Evaluation Branch, Division of Systems Integration, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatories 8(a) and 10 of the 9th Set of Interrogatories, and I hereby certify that the answers given are true to the best of my knowledge.

lAl' w

LARRY

. BELL Subscribed,and sworn to before me this dGayofMay,1982.

4 Rotary Public' My Comission expires: ///

UNITED STATES OF AMERICA 8

NUCLEAR REGULATORY COPtilSSION BEFORE THE ATOMIC SAFETY AND LICENSillG BOAR'6 F

In the Matter of l}

UtilTED STATES DEPARTMENT OF ENERGY l

Docket No. 50-537 PROJECT ttANAGEMENT CORPORATION l

TENNESSEE VALLEY AUTHORITY ll (ClinchRiverBreederReactorPlant)!>l AFFIDAVIT OF JERRY J. SWIFT I, Jerry J. Swift, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Reactor Engineer, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatories

  1. 8a and #10 of the Ninth Set and I hereby certify that the answers given are true to the best of my knowledge.

/),y I

\\

Subscribed and sworn to before me this p f day of May, 1982.

/lU bd W Notary PubMC.,

My Comission expires:

g

o UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l

BEFORE THE ATOMIC SAFETY AND LICENSING. BOARD-

)

l In the Matter of

)

I UNITED STATES DEPARTMENT OF ENERGYh Docket No. 50-537 PROJECT MANAGEMENT CORPORATION I

TENNESSEE VALLEY AUTHORITY h

(ClinchRiverBreederReactorPlant))I AFFIDAVIT OF JOHN V. NEHEMIAS I, John V. Nehemias, being duly sworn, state as follows:

I am employed by the U.S. Nuclear Regulatory Comission as a Senior 1.

Health Physicist, Radiological Assessment Branch, Division of Systems Integration, Office of Nuclear Reactor Regulation.

I am duly authorized to participate in answering Interrogatories #1 2.

and #2 of Section I; #1 and !2 of Section II and #1 through #8 of Section III of the 10th Set and I hereby certify that the answers l

f given are true to the best of my knowledge.

A f. b. On M

Ghn V. Nehem~iar 1

l f

Subscr bed and sworn to before me this (Xdayof May, 1982.

//r1

// b W b Notary Public My Comission expires:

/

l

s UNITED STATES OF AMERICA NUCLEAR REGULATORY C06911SSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ll

)

U.S. DEPARTMENT OF ENERGY h

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION h

TENNESSEE VALLEY AUTHORITY ll (Clinch River Breeder Reactor Plant) h>

AFFIDAVIT OF BILL M. MORRIS I, Bill H. Morris, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a section Leader of the Technical Review Section, Clinch River Breeder Reactor Program Office Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatories #1 through #15 of Section I and #1 through #47 of Section II of the 2nd Set and I hereby certify that the answers given are true to the best of my knowledge.

0 M n 1,v1 d t

BILL M. MORRIS Subscribpd and sworn to before me thisg7//, day of May,1982.

af)lb D 1/h.=

Notary Public l

My Comission expires: //[fA

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION -

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of UNITED STATES DEPARTMENT OF ENERGY l

Docket No. 50-537 lJ PROJECT MANAGEMENT CORPORATION l

TENNESSEE VALLEY AUTHORITY

)

(ClinchRiverBreederReactorPlant))

AFFIDAVIT OF HOWARD B. HOLZ I, Howard B. Holz, being duly sworn, state as fo11cws:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Systems Engineer, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

I 2.

I am duly authorized to participate in answering Interrogatories #1 through #15 of Section I and #1 through #30 of Section II of the 3rd Set and I hereby certify that the answers given are true to the best of my knowledge.

Howard B. Holz

/

Subscribe.j and sworn to before me this //f3 day of May,1982.

/iAb llA%

' Notary PubTic My Comission expires: 7//((p

~

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION v

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

~

In the Matter of

))

UNITED STATES DEPARTMENT OF ENERGY l

Docket No. 50-J37 PROJECT MANAGEMENT CORPORATION

!)

TENNESSEE VALLEY AUTHORITY lll (ClinchRiverBreederReactorPlant)')

AFFIDAVIT OF BILL M. MORRIS 1, Bill M. Morris, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Section Leader of the Technical Review Section, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatories #1 through #7 of Section I and #1 through #28 of the 4th Set and I hereby certify that the answers given are true to the best of my knowledge.

hr'.<)RJ-97ww Bill M. Morris Subscribed and sworn to before me this g day of May,1982.

IEE/Y YUw Motary Public g

My Commission expires: 7//((p

~

UNITED STATES OF A'MERICA NUCLEAR REGULATORY C0tt11SSION BEFORE THE ATOMIC SAFETY AND LICENSING *S0ARD' In the Matter of ll

)

UNITED STATES DEPARTMENT OF ENERGY l

Docket No. 50-537 PROJECT ltANAGEtiENT CORPORATION l

TENNESSEE VALLEY AUTHORITY ll h>

(Clinch River Breeder Reactor Plant)

AFFIDAVIT OF ROBERT J. DUBE I, Robert J. Dube, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Section Chief of Regulatory Activities and Analyses Section, Fuels Facilities Safeguards Licensing Branch, Division of Safe-guards, Office of Nuclear Material Safety and Safeguards.

2.

I am duly authorized to participate in answering Interrogatories in Section III, #1 through #9 of the 6th Set and I hereby certify that the answers given are true to the best of my knowledge.

l UA ROBERT J. DUBE / ~

Subscribed and sworn to before me this UWa of Apr 1,1982.

~d I

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....'ggjgg 7t eritAnyiAND Notary Publ' c

~

g 7L l(

,jg.>n Expos My 1.1982 N

My Comission expires: J l

t UNITED STATES OF AMERICA e

NUCLEAR REGULATORY COMMISSION e BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

))

UNITED STATES DEPARTMENT OF ENERGY I

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION l

TENNESSEE VALLEY AUTHORITY

',1 (ClinchRiverBreederReactorPlant)),

AFFIDAVIT OF CHARLES L. MILLER I, Charles L. Miller, being duly sworn, state as follows:

I am employed by the U.S. Nuclear Regulatory Comission as a 1.

Nuclear Engineer, Effluent Treatment Systems Branch, Division of Systems Integration, Office of Nuclear Reactor Regulation.

I am duly authorized to participate in answering Interrogatory #10 2.

of the 1st Set and I hereby certify that the answers given are true to the best of my knowledge.

cAAvsdL CHARLES L. MILLER Subscr bed and sworn to before me this

] day of May

,1982.

l}HJ /

1l m Notary Publir My Comission expires:

7f

UNITED STATES OF AMERICA I

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARif In the Matter of

))

UNITED STATES DEPARTMENT OF ENERGYh DockeS No. 50-537 9l}

PROJECT MANAGEt1ENT CORPORATION TENNESSEE VALLEY AUTHORITY I

(Clinch River Breeder Reactor Plant) h AFFIDAVIT OF JOHN V. NEHEMIAS 1, John V. Nehemias, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Senior Health Physicist, Radiological Assessment Branch, Division of Systems Integration, Office of Nuclear Reactor Regulation.

I am duly authorized to participate in answering Interrogatory #11 f

2.

of the 1st Set and I hereby certify that the answers given are true to the best of my knowledge.

1 b

/u fe x

@ n V. Nehemias~

Subscribed and sworn to before me this fgdayof May, 1982.

Afl/ /

J/M/ /z/

Notary Public My Comission expires: 7//[fg

t e

UNITED STATES OF AIIERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of p

I UNITED STATES DEPARTHENT OF ENERGYh' Docket No. 50-537 PROJECT MANAGEMENT CORPORATION

))l TENNESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor Plant) )

AFFIDAVIT OF LARRY W. BELL 1, Larry W. Bell, being duly sworn, state as follows:

I am employed by the U.S. Nuclear Regulatory Comission as a 1.

Nuclear Engineer, Accident Evaluation Branch, Division of Systems Integration, Office of Nuclear Reactor Regulation.

I am duly authorized to participate in answering Interrogatory 2.

  1. 9 of the 1st Set and I hereby certify that the answers given are true to the oest of my knowledge.

N

~. ws LARRY

. BELL Subscri and sworn to before me this day of May, 1982.

E L

Kotary Publ W My Commission expires: 'll'in

a UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION :

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of-ll I

UNITEDSTATESDEPARTMENTOFENERGYl l

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION I

TENNESSEE VALLEY AUTHORITY l

l (Clinch River Breeder Reactor i

Plant)

)

AFFIDAVIT OF MICHAEL KALTMAN I, Michael Kaltman, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Regional Planning Analyst, Siting Analysis Branch, Division of Engineering, Office of Nuclear Reactor Regulation.

2.

I am responsible for providing the updated answers to the State of Tennessee Interrogatories, and I hereby certify that the updated answers are true to the best of my knowledge, k

o-

~

Mi@adl Kaltman Subscribed and sworn to before me this p g day of g, 1982.

tal n

otary Public My Commission expires: //[

e a

UNITED STATE,5 OF AMERICA.

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

)

)

UNITED STATES DEPARTMENT OF ENERGY

)

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION

)

TENNESSEE VALLEY AUTHORITY

)

)

(Clinch River Breeder Reactor Plant) )

AFFIDAVIT OF MICHAEL BENDER Michael Bender, being duly sworn, state as follows:

I, 1.

I am employed by the U.S. Nuclear Regulatory Commission (NRC) as a Consultant through a contract between the Clinch River Breeder Reactor Program Office, NRC, and Brookhaven National Laboratories.

I am employed by the Brookhaven National Laboratories as a 2.

Senior Scientist in the Medical Department.

I t

I am duly authorized to participate in answering the March 18,198 3.

Ninth Request for Admissions pertaining to Contention 8b tenumbere i

1 as 11) #1 through i12 and I hereby chrtify that the answers given are true to the best of my knowledge.

4 l

MJ.edkA i,

MICHAEL BENDER Subscribed and sworn to before me this 6 day of May, 1982.

%"R ALDtNT CALLISTER s4_ ; c-2A4E

"'7.7.T.?"fd: 7.t O!**

652-054 2 s e m, c.

m sw= m 5ese, pts Notary Public My Commission expires: M 4o, Ifl3 oO t

a UNITED STATES OF AMERICA

'c NUCLEAR REGULATORY COPf1ISSION,

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD k.-

1 In the Matter of

)l UNITED STATES DEPARTMENT OF ENERGY I

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION

)1 TENNESSEE VALLEY AUTHORITY I

(Clinch River Breeder Reactor Plant) h AFFIDAVIT OF EDWARD F. BRANAGAN, JR.

I, Edward F. Branagan, Jr., being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Radiological Physicist, Radiological Assessment Branch, Division of Systems Integration, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering the March 18, 1982 9th Request for Admissions,Section II, concerning Contention 3 (re-numbered as 2) #7 through #10 and I hereby certify that the answers given are true to the best of my knowledge.

EDWARD F. BRANAGAN, JR.

Subscri ed and sworn to before me this day of May,1982.

(l 0

%/4 ROTARY PUBLIC

{

MyCommissionexpires:7/f

. --

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